If you’re like me, the famous opening sentence to Dickens’ A Tale of Two Citiescalls to mind memories of droning college lectures on Victorian literature that made you yearn for more pleasant surroundings such as the DMV or dentist chair, but it’s also a fitting description of today’s housing and mortgage markets. Given that we’re nearing the end of 2018, it makes sense to use this month’s blog post to take a look at the current state of the mortgage market and some trends to consider as we enter the new year, so here goes.

All real estate is local – except when it’s not

My favorite thing about my job is that I get to travel the country and talk with people across the spectrum of the mortgage business, from MLOs to regulators, and discuss the market with them. While often there are a few common topics of concern raised across different locations, this year was the first in a long time when MLOs in every single region of the country ranked the same two issues in order as the biggest impediment to growth: Lack of inventory and rising mortgage rates.

Of course, those issues are very closely related, as homeowners with low interest rate loans put off potential moves while the refinance market craters at the same time. The good news for mortgage professionals (according to CoreLogic data from July of this year) is that 41% of renters in the 100 hottest housing markets plan to buy a home in the next year, and with unemployment at multi-decade lows and wages beginning to show steady growth, they’re in a good position to follow-through on those plans. Unfortunately, that same data tells us that only 11% of homeowners plan to sell in the same time period, leading to the likelihood that inventory concerns will persist into 2019. While new construction may alleviate some of the pressure, it should remain a seller’s market for much of the next 12 months, even if rising interest rates do lead to a slowing of home price growth.

The incredible shrinking margin

Independent mortgage banks have had (to put it bluntly) a terrible year when it comes to origination profits. In the third quarter, IMBs recorded an average profit of just $480 per loan, which is slightly better than the $118 per loan loss posted in the first quarter, but down year-over-year. Given typical fourth quarter struggles, 2018 is on pace to be the worst year for origination margins since the crash of 2008.

The good news is that companies that own mortgage servicing rights (MSRs) are seeing strong value from them. This should continue, as MSRs tend to be a very stable investment in rising interest rate environments because loan payoffs decrease as refinance volume falls. Perhaps the most important line in the linked article above: “Including all business lines (loan production and servicing), 71% of the firms studied posted a pretax profit in the third quarter. Without servicing, that percentage would have dropped to 52%.” Unfortunately, that does not bode well for IMBs that only participate in the origination side of the business, so look for this winter to bring another wave of consolidation among that segment of the business to the benefit of the larger IMBs that service AND to mortgage brokers who aren’t faced with banker levels of overhead expenses.

Land of opportunities

Fear not, mortgage originators! While the ride is certainly choppy and likely to become more so in 2019, there ARE opportunities to grow your business over the next 12 months. The first thing you need to do, however, is accept that we’re not in Kansas anymore. If you’ve been operating in the confines of the Fannie/Freddie box and/or relying on refinances for more than 20% of your income, there are some things you can do NOW to set yourself up for success:

Get out of your comfort zone. Examine the full suite of products your company offers. Read and memorize guidelines and niches! As volume and profits shrink, the credit box is expanding. To date, much of this guideline expansion has been in the jumbo QM loan market, but I expect the non-QM market to pick up significantly at all loan levels as we go through the winter. This will be the first “slow period” in a long while where the refinance market is almost all needs-based (cash-out, divorce settlements, etc.), and lenders will need to find ways to fill the refi void. If you’re the market-watching type, keep an eye on companies like Verus Mortgage Capital and Neuberger Berman as they continue to bring non-QM securities to market. If investor appetite increases for these mortgage-backed securities, expect more companies to jump into the non-QM pool with both feet. The key is to know your product offerings inside and out, be able to explain them to consumers and referral sources and lend responsibly. (State regulators will be watching.)

Get back to basics. When purchase business accounts for 80% of residential originations, you can’t afford to be lax in maintaining your referral sources and looking for new ones, especially among real estate agents. No, this doesn’t mean you should consider violating RESPA’s prohibition on referral fees. What it DOES mean is that you need to be in regular contact with those who trust you and add value to their business instead of just bringing doughnuts, asking for referrals and taking them for granted. How do you add value? One of the easiest ways is to show them how your expanded product selection and knowledge can translate into more closings for both of you. With technology tools like social media and CRM platforms, there really is no excuse for not getting your name out there (in a compliant manner, of course). Don’t let others eat your lunch; market yourself like it’s 1999.

Go where the business is. Work on a strategy to penetrate sectors of the market that are either underserved or outperforming (or both). Wondering where to start? Think inventory shortages. If people are remaining in their homes because their next “dream home” isn’t available, that doesn’t mean they’re satisfied with the status quo. In fact, renovation spending has been on the rise for a while now. Combine that with the fact that there’s almost $6 billion in tappable equity available, and renovation lending becomes a very attractive option to add to your suite of products. If you’re not able to go that route, consider finding ways to service the most consistently expanding demographic in home purchases: the Hispanic population. This doesn’t mean that you need to be multilingual (though there are certainly myriad opportunities to service the Limited English Proficiency – or LEP – market for those who are), but it does mean that you may need to brush up on underwriting guidelines for situations that arise more often in this community like gift funds, non-occupying co-borrowers, wage earners with multiple employers and multifamily dwelling considerations. Also, please consult management about fair lending considerations that may arise here so that you can do things the right way.

More market information

If you like forecasts and economic news, there’s certainly no shortage of it this time of year. Here are three of my must-reads:

As the year comes to a close, I want to thank all of you for your support of Real Estate Institute and my monthly ramblings. It’s because of you that I look forward to coming to work every day and pursuing my passion for residential finance and education. I wish you all a safe and happy holiday season, and I’m looking forward to continuing this journey in 2019!

Happy Originating,

Peter

Real Estate Institute offers top-rated Mortgage Loan Originator Continuing Education and Pre-License courses in all three formats: Classroom, Live Webinar and Online, Self-Study. These courses were designed BY loan originators FOR loan originators covering topics you need to know to navigate today’s ever-changing lending landscape.

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They say that every person needs a passion and/or a hobby. I have two, one of which is regulatory compliance in mortgage lending. Unfortunately, that doesn’t make any of the various approved lists of hobbies for men, which is likely why I’m often found alone next to the bar or canape table at cocktail parties. (However, my other passion, darts, does make several of the lists, so there’s that.)

Thankfully, there is a support group where people like me can get their daily dose of various and sundry compliance scenario questions to mull over and comment upon. It’s an email listserv called RegList, and it has some of the most brilliant compliance minds in the country on it. In fact, if your job description includes anything related to mortgage compliance, I recommend you join us; membership is currently FREE, and we even get together for the occasional cocktail at various industry conferences (canapes optional). Just remember, what happens in compliance stays in compliance.

Recently, there was a question posted to the group that got me thinking about how much MLOs really understand about the requirements and timelines for TRID disclosures. It involved a situation where the borrower received a revised loan estimate four business days prior to closing (the last day that a revised LE can be provided under TRID) but did not SIGN the LE until the next day, which is the same day they received the Closing Disclosure.

The ultimate question was, can a borrower SIGN a revised LE on the same day they RECEIVE the initial CD, and the reason I’m discussing it here is there’s a very real possibility that you’ll encounter this exact scenario on one of your files.

To answer this question, we need to look to Section 1026.19(e)(4)(ii) of Regulation Z, which states, in part, “the creditor shall not provide a revised version of the… [Loan Estimate] … on or after the date on which the creditor provides the… [Closing Disclosure]. The consumer must receive any revised version of the…[Loan Estimate]…not later than four business days prior to consummation.” (All emphasis mine.)

Here’s where I think MLOs and others who are not interacting with the rule on a daily basis may get confused: The words PROVIDE and RECEIVE are NOT synonymous with the word SIGN. In fact, Section 1026.37(n) of Regulation Z and the official commentary to this section of the rule make it clear that a signature is not required on the Loan Estimate! The creditor is free to include a signature line for the consumer to “confirm receipt” of the disclosure or NOT to include it at its sole discretion.

Yes, as a matter of course, virtually all creditors elect to use the version of the form with the signature line because it enables them to more easily track timelines and sell loans to certain investors. However, from a pure compliance perspective, it makes no difference when – or indeed even IF – the borrower actually signs the document. Thus, as long as the creditor can prove that the borrower RECEIVED the revised LE at least four business days prior to closing, providing the CD on the same day the borrower signs the revised LE is compliant so long as the CD meets all other timing requirements. Keep in mind that, if you’re providing these disclosures electronically, you must comply with all requirements in the federal E-SIGN Act regarding consent and delivery.

This is just another example of why our compliance management systems (CMS) are so important. While some investors may initially be unwilling to purchase the loan described above simply because of the signature date on the revised LE, being able to provide proof that the LE and CD were DELIVERED in accordance with Regulation Z requirements may save you from a dreaded buyback or unsaleable loan scenario.

Happy originating,
Peter

Real Estate Institute offers top-rated Mortgage Loan Originator Continuing Education and Pre-License courses in all three formats: Classroom, Live Webinar and Online, Self-Study. These courses were designed BY loan originators FOR loan originators covering topics you need to know to navigate today’s ever-changing lending landscape.

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By now, you probably received this notice from the IDFPR’s Division of Real Estate (DRE), which advises all real estate licensees that beginning October 1, paper applications for new licenses and renewals (for most license types) will no longer by accepted. Instead, applicants must use the Online Services Portal.

The move to online licensing significantly speeds up the licensing process by automating tasks that formerly required more than one person or department to intervene.

When to Use Online Licensing Services

Beginning in October, the Online Services Portal should be used to:

Apply for a new license

Renew an existing license

Request a change of sponsorship

Terminate sponsorship

Update or make changes to licensee information

What About the 45-Day Sponsor Permit Card?

The new online workflow eliminates the need for a temporary sponsor permit card. As a result, this document will no longer be accepted by the DRE. Instead, Leasing Agents, Brokers, and Managing Brokers must use the Online Services Portal to request that their license be sponsored by a Managing Broker or licensed organization. Using this new system, a change of sponsorship can be completed within days.

Special Notice Regarding Branch Renewals

Last month, Gov. Bruce Rauner signed HB5210 into law, which eliminated the requirement for licensed real estate businesses to obtain an additional license for each of their branch office locations. This change will reduce costs and administration for real estate brokerages.

However, it will take some time for the DRE to fully implement this change and put in place an alternate process to ensure the DRE remains aware of locations where a brokerage conducts business with consumers. In the interim, these licensees must renew their branch license, but the DRE will waive the fee typically required for renewal. Branch license renewals are due by October 31, 2018 and may be renewed online here.

In Closing

Most licensees are having a positive experience with the new systems and online features, but as with any new process, there will be some quirks and problems to overcome. For example, we’ve already seen that the Online Services Portal lacks key features required by larger organizations, such as the ability to delegate access to non-licensed users who are responsible for license administration within the organization. Thankfully, the DRE has been very responsive to feedback and ideas. They are acting fast to fix bugs and make long-term improvements through ongoing investment in the technology.

If you have ideas for updates or new features for the Online Services Portal, let us know. We frequently participate in IDFPR meetings, sharing feedback we’ve received. You can comment on this blog post or send us feedback through the Contact Us form on our website.

Real Estate Institute has been a leader in real estate education for 25 years, offering top-rated Continuing Education and Pre-License courses in multiple formats: Classroom, Live Webinar and Online Distance Education. Real Estate Institute’s team of experts is standing by to answer questions about your requirements, our courses and the renewal process. Please don’t hesitate to contact us at 800-995-1700.

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After nearly a decade of asking, Illinois insurance producers can finally complete their 3-hour ethics continuing education requirement via webinar. The bill allowing for ethics webinars was signed into law by Gov. Bruce Rauner on August 14, 2018, and the Department of Insurance began approving webinars from course providers (including Real Estate Institute) a few weeks ago.

Although the new law provides a new method of ethics course delivery for insurance producers, the change is not applicable to public adjusters. According to the DOI, licensed Illinois public adjusters must still earn 3 hours of ethics credit by attending a live, in-person class.

The law also creates an education advisory council that will be charged with making recommendations to the state about insurance courses, curriculum and instructor qualifications.

Real estate brokers help to create successful transactions for their clients, but they often participate in their own transactions, too. This may include buying or leasing a primary residence, the purchase or sale of investment property, etc.

When an Illinois licensed real estate broker engages in a transaction, there are special disclosure requirements that can be easily overlooked. In general, these requirements are in place to ensure that the other party in a transaction is aware of the licensee’s status – because the licensee is perceived to have more knowledge and therefore may be able to take advantage of the other party.

Failure to disclose that you are a licensee is a violation of license law that may expose you to penalties up to and including revocation of your license.

Key Requirements

Disclosure must be made to all parties when a licensee is selling, leasing or purchasing any interest in real property.

Disclosure must be made in writing.

You may do so when you first meet or interact with the other party or include the disclosure as part of your written offer.

If you include the disclosure on a contract that you submit, avoid adding a small note next to your signature (on the last page). In the past, the IDFPR has suggested that licensees add the required text in large/clear print at the top of the contract to ensure that the receiving party sees it before they review and sign the contract.

Disclosure requirements apply to the following parties:

Sole owners.

Joint tenants and tenants by the entirety.

Land trusts.

General partners in a partnership.

Officers, directors, majority shareholders and controlling shareholders of a corporation.

Managers or majority or controlling members of a limited liability company.

Anyone else with a direct or indirect interest in the subject property.

Business Entities

It’s noteworthy that licensees often get into trouble when a business entity is involved in the transaction. It’s critical to remember that brokers must disclose their status even when they are not personally a party to the contract. For example, Happy Investments LLC may be the buyer, but if Lucy Licensee is a manager of that LLC, she must still make the required disclosure.

Final Advice

Lastly, although it’s not required by law, it never hurts to also communicate orally to help ensure the other party has received your notice. You may even consider asking for a written acknowledgement of the disclosure.

Real Estate Institute has been a leader in real estate education for 25 years, offering top-rated Continuing Education and Pre-License courses in multiple formats: Classroom, Live Webinar and Online Distance Education. Real Estate Institute’s team of experts is standing by to answer questions about your requirements, our courses and the renewal process. Please don’t hesitate to contact us at 800-995-1700.

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Gov. Bruce Rauner has signed into law the bill known as SB 2615, which amends the Residential Mortgage License Act of 1987 and makes minor changes to advertising requirements. The bill, which passed both houses of the Illinois Legislature unanimously, removes the need for mortgage companies licensed by the IDFPR to use the phrase “Illinois Residential Mortgage Licensee” in all advertisements.

As of August 10, 2018, mortgage advertisements in Illinois “must reference the Nationwide Multistate Licensing System’s Consumer Access Website” (www.nmlsconsumeraccess.org). In addition, all mortgage advertisements must now include the company’s NMLS unique identifier.

Now is a good time for companies to do a thorough review of their advertising policies and procedures to ensure continued compliance with state and federal advertising requirements. As always, MLOs are reminded that social media pages and posts promoting their employment are considered advertisements and must be compliant with all relevant laws. (We’ll discuss this further in our comprehensive CE class this year.)

Thanks to the folks at the Greater Midwest Lenders Association (www.GMLAonline.org) for spearheading this legislative effort to standardize Illinois advertising law with those found in many other states.

Peter

Real Estate Institute offers top-rated Mortgage Loan Originator Continuing Education and Pre-License courses in all three formats: Classroom, Live Webinar and Online, Self-Study. These courses were designed BY loan originators FOR loan originators covering topics you need to know to navigate today’s ever-changing lending landscape.

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Over the past few years, the Illinois Department of Financial and Professional Regulation (IDFPR) has taken big steps to offer more information and services at its website. The resulting features offer some efficiencies that most real estate sponsoring brokers haven’t yet discovered. Here are four features you should use:

This easy-to-use lookup tool enables consumers, licensees, and others to check the status of a professional license. For sponsoring brokers, it offers these important features:

Check to see whether your personal or business license is in good standing. (Look for an “ACTIVE” status.)

View a list of all licensees (e.g., Managing Brokers, Brokers, Leasing Agents) who the sponsoring broker currently sponsors. (See the list of “subordinate” licensees.)

Using the above list, you can confirm that the sponsored licensees have an “ACTIVE” status. TIP: It’s especially important to do so at the start of a renewal period. It’s not uncommon for licensees to overlook the renewal … and you need to be sure that they are currently licensed to practice.

This is a big one. Now, sponsoring and sponsored licensees can request a change of sponsor without relying on paper forms. This means that it’s no longer necessary to use the 45-day sponsor card and mail in the corresponding form and fees to the state.

To use this feature, you must create an account and login to the Online Services Portal . Once logged in, click the Online Services menu, then Licensure Options.

Using this feature to initiate a change of sponsor request will trigger an automated, online process. The terminating sponsoring broker, new sponsoring broker and licensees will all be notified of the request by e-mail. Below is an example of the message a sponsoring broker might receive.

The affected licensees will have three days to respond affirmatively. If the required approvals are not provided, the request will be cancelled.

TIP: Be sure to have your e-mail address on file with the IDFPR. You can provide or update that here.

Follow Real Estate Institute’s blog to be notified when we post more tips and other important information about the regulation of Illinois real estate licensees.

Real Estate Institute has been a leader in Illinois real estate education for 25 years. Our students have consistently outperformed other state exam candidates. A reputation for highly rated instructors and superior customer service explains why we have over 150,000 alumni nationwide.

So, without further ado, here are the five parts of this much larger bill that are likely to affect originators and mortgage compliance professionals.

Transitional MLO licensing. Without a doubt, this is the most important change for anyone on the front lines of our business, and one that the Mortgage Bankers Association has been advocating since the SAFE Act went into effect. The provision gives MLOs who work for depositories a 120-day window to originate loans after transitioning to a nonbank while securing their state license, meaning they would not need to lose valuable work time and income fulfilling the licensing provisions before speaking to consumers. This same 120-day grace period will also apply to currently licensed originators who wish to obtain a license in another state.

A small bank exemption from expanded HMDA reporting. Banks that originate fewer than 500 HELOCs and closed-end mortgages in a year have been exempted from reporting the expanded HMDA data points that went into effect with originations after January 1, 2018. Despite what you may have heard, this does NOT exempt these institutions from Regulation C altogether, merely from reporting the new data points such as disaggregated demographic information. This provision does not make any changes for other institutions, including nonbanks.

Eliminating the need for an additional 3-day waiting period when the APR decreases. Before you jump for joy at this one, the legislative language applies directly only to High-Cost mortgage loans. Although given the current leadership at the Bureau, it is likely to clarify through regulation or official interpretation that the same provision applies to loans that are not High-Cost as well (the Bureau has taken that position informally since TRID was enacted).

Allowing consumers to freeze their credit reports without cost. This provision is a direct result of the massive Equifax data breach that shook the country in 2017. While credit freezes (that stop anyone from accessing a consumer’s credit file) have been around since the passage of the Fair and Accurate Credit Transactions Act, there has been a cost associated with them. Removing this cost will likely lead to more consumers placing freezes on their reports (and more MLOs needing to ask clients to unfreeze them to proceed with an application). Under the law, the bureaus are also required to inform consumers that these no-cost freezes are available.

Providing Qualified Mortgage protection to bank portfolio loans. Depository institutions with assets under $10 billion receive QM protection on loans that they retain in portfolio without needing to follow all the documentation requirements in Appendix Q of the Qualified Mortgage rule. Before you start reliving 2007 however, keep in mind that such loans will still require verification of applicant income and assets, comply with prepayment penalty restrictions in the QM rule and not carry any interest-only or negative amortization features.

Where do we go from here?

While Congress is likely done with financial regulatory issues (at least for this session), the CFPB is, of course, under no pre-midterm election pressure. In fact, they’re scheduled to reexamine the QM Rule in 2018 due to the mandatory five-year review period specified in the Dodd-Frank Act. We know through various speaking engagements by Acting Director Mulvaney that this process is likely to lead to significant changes to the rule, although the scope and extent of those changes are not yet known. One of the areas of the rule that seems ripe for change is the 43% Debt-to-Income requirement exemption given to loans eligible for sale to Fannie Mae and Freddie Mac. Remember, this exception is temporary and is currently scheduled to sunset in January 2021. Thus, if not extended or made permanent, Fannie and Freddie loans would begin to be subject to the 43% DTI cap for QMs at that time. This could have a big effect on the marketplace by moving otherwise qualified loans out of the conventional conforming space and into FHA (adding risk to taxpayers), so look for this to be one of the focal points in an amended QM rule.

While we’re on the topic of regulation, remember the United States has a dual regulatory system where both federal and state governments have a say in regulating many financial services entities. It’s very likely that, as the CFPB pulls back on certain regulations, some states will move to continue or tighten them. Thus, compliance managers and MLOs alike need to remain focused on statehouses across the country for potential changes affecting rules in states in which they are licensed. This is especially true if there are leadership changes at the state level as a result of the off-year election results in November.

See you next month!

Peter

Real Estate Institute offers top-rated Mortgage Loan Originator Continuing Education and Pre-License courses in all three formats: Classroom, Live Webinar and Online, Self-Study. These courses were designed BY loan originators FOR loan originators covering topics you need to know to navigate today’s ever-changing lending landscape.

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The license renewal deadline for Illinois real estate Brokers is only weeks away. For those who have yet to renew their licenses, this can cause panic. But it doesn’t have to.

Follow the steps below to maintain your license. Each step offers tips on the fastest way to stay compliant (so you can keep working).

Complete Your Education

Brokers in Illinois are required to complete education before renewing their license. The type of education depends on what date your license was issued. Find out the original issue date of your license by checking the Illinois Department of Financial and Professional Regulation (IDFPR) license lookup page at their website.

Brokers whose licenses were issued before 2/1/2016 require 12 hours of core and elective continuing education. While live classes are permitted, self-study or online distance education (new for 2018), are the fastest and most flexible options. Self-study courses can be completed anywhere, anytime and require a proctored exam. Online distance education and classes don’t require a final exam, based on recent real estate license law amendments. Finding live classes in your area at this late date may be a challenge. We recommend trying out online distance education. Real Estate Institute offers convenient continuing education options here.

Brokers whose licenses were issued from 2/1/2016 – 1/31/2018 require post-license education. Half of this 30-credit-hour requirement must be delivered via interactive instruction, such as a live class or webinar. With limited time remaining, webinars are recommended because they offer very flexible attendance options – review your post-license education options.

Brokers whose licenses were issued after 1/31/2018 won’t have to renew until 2020, so no education is required at this time. Even so, these Brokers should complete their post-license education well before their deadline to get it out of the way so they don’t have to worry about it later. (Tip: You can get started as soon as 5/1/2018.)

Renew Your License

Most Brokers know that they must pay the renewal fee to the Illinois Department of Financial and Professional Regulation (IDFPR) but are unsure of the exact process. Read the following for specific details about the renewal process:

After completing your required education, you may renew the license. The IDFPR license renewal fee is $150 for the two-year period. (Tip: This close to the deadline, it’s important to find an education provider that will quickly issue your certificate of completion.)

The IDFPR strongly encourages Brokers to renew online. You may have received a PIN via e-mail from the IDFPR. (Tip: It’s not needed to renew.) The license number, plus one of the following is needed to renew: Social Security number, date of birth or the IDFPR-issued PIN. A paper-based renewal form is also available with this information.

Real Estate Institute has been a leader in real estate education for 25 years. Our team of experts is standing by to answer your questions about your requirements, our courses and the renewal process. Please don’t hesitate to contact us at 800-995-1700.

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The Illinois Department of Financial and Professional Regulation (IDFPR) recently e-mailed Brokers, announcing that they are officially “In Renewal.” The department is now accepting online license renewal applications.

If you didn’t receive this announcement, you may need to update your contact information with the state to receive future notices. To easily update or add your e-mail address, click here.

Remember, you cannot renew your real estate license until your required education is complete. It’s important that you follow these instructions for a timely renewal.

The current Broker renewal period began May 1, 2016, and ends April 30, 2018. If you complete CE or Post-License education with Real Estate Institute, our school reports your course completion directly to the IDFPR.

Step 2 – Submit Your New License Application

After you have completed your CE or Post-License requirement, you must renew your license with the IDFPR. There are two ways to renew your license:

Apply Online – The IDFPR permits online license renewal applications to be submitted up to 90 days before the license expires. This option allows you to complete the entire renewal application and pay online. Click here to apply online.

Mail Your Application – The application can be completed online, printed and mailed with payment. If you use the paper application, we strongly recommend that you send it to the IDFPR via USPS Certified Mail so that you receive confirmation of delivery. Delivery confirmation will be critical in the event of a delay in license renewal. It will likely take the IDFPR several weeks to process your application.

Real Estate Institute has been the local leader in Illinois real estate education for over 25 years. More Brokers choose Real Estate Institute than any other provider for their required license renewal education every season. Our team of experts is standing by to answer your questions about your requirements, our courses and the renewal process. Please don’t hesitate to contact us at 800-995-1700.

Upcoming Deadlines:

A considerable amount of care has been taken to provide accurate and timely information
in these updates. However, any ideas, suggestions, opinions or general knowledge presented
in this text are those of the authors and other contributors and are subject to local, state
and federal laws and regulations, court cases and any revision of the same. The reader is
encouraged to consult legal counsel concerning any points of law.

The updates should not be used as an alternative to competent legal counsel.